Guerrilla Discovery

State and Federal (This started in the new 2019 edition)



The Most Complete, Form-Filled, Case-Filled, Cite-Filled, How-To Filled, Comprehensive Book On Discovery Ever Written. PERIOD. It thoroughly covers all weapons of discovery (Requests for Admissions, Interrogatories, Notices for Production and Inspection, Demands for Physical Examination, Depositions, and Subpoenas); it directs and guides all manner of submission and enforcement. Guerrilla Discovery is the only single source that has:


  • Tons of explosive powerful forms for discovery demands, objections, and opposition
  • Over 2,000 annotations with cites of key cases, authorities, and comments
  • A unique annotated list of EVERY discovery defense/objection known to mankind
  • Tactics, rules, decisions, statutes, tips, samples, checklists, and protocols
  • An arsenal of strategies, counter-strategies, and anti-counter strategies
  • Electronically Stored Information (ESI) resources, sources, and guides
  • Pounds of sample interrogatories, RFA’s, notices, and demands
  • Official eDiscovery court-approved protocols and conventions
  • All approved official judicial counsel form interrogatories
  • Coverage of predictive coding and technology-assisted review (TAR)
  • Sample letters to smoke out every type of enemy obstructionism
  • Valuable training for evidence and objections in general
  • A step-by-step roadmap for noticing, taking, and defending depositions
  • Guides for avoiding and handling dirty discovery tricks
  • Key Rules uniquely and thoroughly Annotated
  • Special Glossary for electronic and digital discovery
  • An armada of case law supporting every key issue
  • What to say, and what not to say at depositions and motions
  • Basically – Everything you need for Discovery in one book

Guerrilla Discovery is a complete, comprehensive arsenal of information specifically tailored for planning, conducting and executing discovery. It likewise provides defensive information and counteroffensive chess-like strategies for every discovery attack. Guerrilla includes:


  • Extensive Case Citations
  • Updated Rules
  • Detailed Strategies for the 6 Discovery Devices:
    • Depositions
    • Requests For Admissions
    • Interrogatories
    • Notice For Production
    • Notice For Inspection
    • Notice For Physical/Mental Examinations
  • Model Forms (For all devices)
  • Extensive Annotated Forms
  • Comprehensive and Extensive Form Interrogatories
  • Extensive Checklists
  • A List of Every Possible Defense and Opposition to Discovery
  • Sample Motion Arguments
  • Sample Deposition Questioning
  • Mini-Crash Courses in Evidence

Most lawsuits are engulfed in quarrelsome discovery fights. Coercion and confrontation are often necessary to obtain evidence on the hotly-contested issues. To help you win more of these important discovery skirmishes, Ashley Lipson’s Guerrilla Discovery offers dozens of clever strategies, novel arguments, direct answers, cautionary instructions, helpful timelines, tactically-annotated rules, and over one hundred innovative forms that will help you:


  • Capture evidence establishing your claims and defenses
  • Secure admissions
  • Settle issues and disputes
  • Impeach the opposition and its witnesses
  • Uncover what the opposition is hiding
  • Learn what the opposition has on you
  • Handle defiant deponents and uncooperative attorneys
  • Control the complexities of e-discovery

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